Documentation:Torts/Indigenous dispute resolution

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TORT LAW
CASEBOOK
Introduction
Dignitary Torts
Defamation • Discrimination • Harassment • Intentional infliction of mental suffering • Invasion of privacy • Trespass to the person
Property Torts
Interference with goods • Interference with land • Non-natural use of land • Private nuisance • Public nuisance
Negligence Tort
Duty of care • Breach of duty • Damage • Causation • Remoteness
Negligence Categories
Employment • Environmental pollution • Harmful products • Hosting patrons and guests • Infliction of mental injury • Misrepresentation • Occupation of premises • Professional services • Public authorities • Pure economic loss • Relational economic loss • Rescuers • Shoddy goods or structures • Treatment of indigenous children • Unborn children
Dishonesty & Abuse of Position Torts
Abuse of process • Breach of confidence • Conspiracy • Fraud • Inducing breach of contract • Injurious falsehood • Intimidation • Malicious prosecution • Misfeasance in public office • Passing off • Spoliation • Unlawful interference with economic interests
Strict Liability
Keeping dangerous animals • Non-natural use of land • Ultrahazardous activities • Vicarious liability
Defences
Apportionment of liability • Consent • Defamation defences • Defence of property • Denials • Excuses • Illegality • Legal authority • Limitation • Necessity • Self-defence
Remedies
Apologies • Damages • Injunctions • Insurance • Legal costs • Mitigation • Proprietary
Tort Law & Legal Systems
Charter values • Class actions • Concurrent actions • Constitutional torts • Indigenous dispute resolution • No-fault compensation schemes
Tort Theory
Instrumental theories • Constructive theories • Critical theories • Reflexive theories
Study Resources
1L strategy • Answer exercises • Quizzes • Beswick's course site • Opening Up Tort Law Project
Index
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Indigenous understandings of dispute resolution
Part of working towards reconciliation between Canada and Indigenous peoples involves recognizing Indigenous customs, values, and aspirations.[1] However, despite some constitutional protection afforded by The Constitution Act,[2] Indigenous perspectives and legal orders do not always have adequate opportunities to operate and develop.[3]

In more recent years, common law courts have sometimes referred to Indigenous views in their decision-making process.[4] Scholars suggest that further steps can be taken to recognize and respect Indigenous legal traditions.[5] Doing so would allow Indigenous peoples to grow socially, politically, and economically in accordance with their own values while improving the relationship that Indigenous peoples share with the Crown.[6]

Indigenous influence on common law development

Although the common law is a system that originally evolved from the English royal courts of justice,[7] courts nowadays have considered that English principles and voices should not be the only ones that inform common law development. In particular, courts in Canada[8] and New Zealand[9] have at least attempted to take Indigenous perspectives into account in their judicial analyses.

Indigenous perspectives in aboriginal and treaty rights

The area of Canadian aboriginal and treaty rights law requires that courts strive for "the reconciliation of aboriginal peoples and non-aboriginal peoples and their respective claims, interests and ambitions."[10] This means that courts may wish to give due regard to Indigenous ways of governance.

In Anderson v. Alberta, Beaver Lake Cree Nation sued the government for having allowed Beaver Lake's lands to be taken up for industrial and resource development.[11] Beaver Lake applied for advanced costs to fund its litigation efforts.[12] As part of the test for advanced costs, the applicant must prove impecuniosity, meaning they "genuinely cannot afford to pay for the litigation."[13] The impecuniosity requirement is guided by the condition of necessity and the applicant's pressing needs.[14] Beaver Lake argued that it met this criteria because its resources needed to go toward other priorities,[15] such as addressing poor housing and infrastructure and high levels of unemployment and social assistance.[16] The Supreme Court of Canada found that "[i]n assessing impecuniosity, a court must respectfully account for the broader context in which First Nations governments such as Beaver Lake make financial decisions."[17] As such, the court should approach the impecuniosity requirement by understanding the First Nation's pressing needs through the perspective of its government.[17]

The need to involve the Indigenous perspective in coming to a fair judicial decision was also highlighted in Restoule v. Canada. There, the Anishinaabe alleged that the Crown had breached an annuity provision that formed part of their treaty agreement.[18] The Crown was of the view that it need not increase the amount of annuity as per the treaty's augmentation clause, because the Crown had "unfettered discretion" as to when and whether to increase the annuity, which the Crown alleged had been communicated to the Anishinaabe.[19] The courts disagreed. The Ontario Court of Appeal affirmed the trial judge's finding that the Anishinaabe perspective would not have allowed for sole or unfettered discretion, as it would have been inconsistent with their conceptions of leadership.[20] As a result, the Crown's alleged discretion was "unlikely to have been what the Anishinaabe understood from an interpretation and explanation of the augmentation clause."[20]

On appeal, the Supreme Court of Canada recognized Anishinaabe’s system of law and governance:[21]

The Anishinaabe’s system of governance and their relationship with the Crown have always been based on the values of respect, responsibility, reciprocity, and renewal. The Anishinaabe sought respect for their jurisdiction and their authority to conclude agreements to share their territory. They acted with a sense of responsibility to ensure their people could continue to depend on the land for sustenance, shelter, medicines, and spiritual well-being. Reciprocity, essential to the formation of alliances, meant that a gift would attract a reciprocal gift of commensurate value, based on the idea of mutual interdependence. This value reflects the notion that people must rely on one another to survive, not simply as an economic necessity, but also as a moral imperative. Renewal invoked the idea that relationships, such as the treaty relationship with the Crown, are ongoing and must be renewed continually.

The Supreme Court rejected the Crown's claim to unfettered discretion, holding that "[t]he Crown must exercise its discretion, including its discretion as to how often it turns its mind to increasing the annuity, diligently, honourably, liberally, and justly, while engaging in an ongoing relationship with the Anishinaabe based on the values of respect, responsibility, reciprocity and renewal."[22]

Indigenous principles and New Zealand common law

Recent case law emerging from New Zealand has made the jurisdiction an interesting case study for the incorporation of Indigenous principles in the common law. The courts there have shown a willingness to evaluate the validity of novel claims in tangent with the perspectives advanced by Indigenous principles, and to allow Indigenous principles to inform the development of the common law more broadly.[23]

An interview with activist Mike Smith
A factory at the end of a winding road and next to a stretch of grass.
A factory in Longburn, New Zealand belonging to Fonterra, one of the seven defendant companies in Smith v. Fonterra.
The plaintiff in Smith v. Fonterra speaks to Stuff News about his activism and work on climate change.
Incorporating Māori concepts in NZ common law
In this episode of Law Report, Justice Joe Willams, the first Māori member of New Zealand's Supreme Court, shares how courts in NZ are adopting First Nations concepts in the common law.[24]

In Smith v. Fonterra, the plaintiff, an elder of Ngāpuhi and Ngāti Kahu, sued seven major greenhouse gas emitting companies in New Zealand, alleging that their emissions constituted public nuisance, negligence, and a proposed novel tort involving a legal duty to cease materially contributing to climate change.[25] The plaintiff pleaded that tikanga Māori should inform "the reach and content of his causes of action" as well as the common law of New Zealand in general.[26] Tikanga refers to Māori customary practices or behaviours.[27]

The plaintiff structured his claims around tikanga principles, asserting a whakapapa (genealogical) and whanaungatanga (kinship) connection to the whenua (land), wai (fresh water) and moana (sea).[28] According to him, his tikanga-based connection to the environment meant that the defendants' harm to the environment of Mahinepua C was also harm to himself and his family.[28] While counsel for the defendants argued that generalized references to tikanga were insufficient to prove the alleged torts,[29] counsel for the plaintiff submitted that specific aspects of tikanga were helpful in framing the claims in new ways, for example, by countering the common law's understanding of proximity based on individualism.[30]

On a strike-out appeal, the Supreme Court of New Zealand emphasized that the loss alleged by the plaintiff is at least partially tikanga-based, and as a result, it will be necessary to engage with tikanga when addressing the damage that might have been sustained.[31] At trial, the judge "will need to grapple with the fact that Mr Smith purports to bring proceedings not merely as an alleged proprietor who has suffered loss, but as a kaitiaki acting on behalf of the whenua, wai and moana—distinct entities in their own right."[32] Tikanga understandings of loss, which are sometimes neither physical nor economic, may also be different than what is typically recognized as loss in the common law system.[32]

Smith v. Fonterra is not the first case in which Indigenous principles have guided the common law in New Zealand. In Attorney-General v. Ngati Apa, the Court of Appeal made it clear that Māori land rights derived from tikanga had been cognizable at common law since the common law's introduction in 1840.[33]

The Supreme Court of New Zealand reiterated a similar sentiment in Takamore v. Clarke, Trans-Tasman Resources Ltd v. Taranaki-Whanganui Conservation Board, and Ellis v. R (Continuance): tikanga was the first law of New Zealand and should continue to influence the common law as appropriate.[34]

Indigenous legal orders

Indigenous laws are built upon Indigenous legal orders, which are traditions specific to Indigenous communities, including relationships to the land, creation stories, customs, processes of deliberation and persuasion, rules, and codes of conduct.[35]

Reviving Indigenous law as a source of Canadian law
This episode of the Modern Law podcast discusses how Indigenous law may be incorporated into the Canadian legal system.[36]

The Canadian legal landscape has generally not provided a welcoming space for Indigenous legal orders. Professor Coyle has outlined how, for most of its history, Canada has attempted to suppress the autonomy of Indigenous communities by restricting their ability to self-govern based on their values.[37] One example of these efforts lies in the 1867 enactment of the Indian Act, where the Canadian government imposed non-Indigenous ways of governance upon those of Indian status.[37] Although section 35 of the Constitution[2] purports to recognize and affirm existing Indigenous rights, Indigenous laws "are often not valued as law when they collide with the laws of Canada’s dominant legal orders."[38]

Constitutional protection of Indigenous rights
The Constitution Act, 1982, Schedule B to the Canada Act 1982 (UK), 1982, c 11, s 35(1).
Recognition of existing aboriginal and treaty rights

35 (1) The existing aboriginal and treaty rights of the aboriginal peoples of Canada are hereby recognized and affirmed.

The last couple of decades have brought some promising developments as the Supreme Court of Canada recognized in several Aboriginal and treaty rights cases that Indigenous laws survived the assertion of Crown sovereignty. Even so, the Court has not yet applied an Indigenous legal concept to resolve an Aboriginal rights or treaty dispute.[37] Critiques of Canadian judicial method contend that despite references to reconciliation, the legal tests developed by the courts fail to protect Indigenous self-determination, and the recognition of Aboriginal land title does not fully encompass a right to exercise jurisdiction over that territory.[39]

Some scholars warn against the danger of trying "to filter Indigenous legal orders through the lens of liberal constitutionalism" because Indigenous laws cannot be removed from the lifeworlds that give rise to them.[39] Implementing them within Canada's political and legal architecture effectively does violence to Indigenous laws and reinforces colonialism.[39] Professor Karen Drake recommends a novel forum for the resolution of disputes between Indigenous peoples and Canadian governments, one grounded in Indigenous processes and constitutionalism instead of the settler legal system.[40] The two main functions would be (1) to provide training to Canadian government representatives on Indigenous constitutional orders; and (2) to provide facilitators who would guide Indigenous dispute resolution procedures (i.e. talking circles).[41] The forum would also remove the need for hefty litigation costs.[40]

Indigenous laws and methods of resolution

Indigenous laws have been described as "non-prescriptive, non-adversarial, and non-punitive", and "[t]hey generally promote values such as respect, restoration and consensus and are closely connected to the land, the Creator and the community."[42]

Naturally then, Indigenous methods of dispute resolution differ significantly from the adversarial nature of the Canadian litigation system. For example, certain concepts that are deeply embedded in Western legal systems, such as "liability" and "punishment" often do not exist in the context of Indigenous dispute resolution.[43] Instead, Indigenous dispute resolution procedures generally aim to restore collective harmony between the affected parties and to reach an outcome that satisfies those parties.[43] Examples of traditional methods of Indigenous dispute resolution include community mediation circles, Elders sentence advisory panels, and community sentencing committees.[44] It is important to note, though, that while Indigenous communities share some similarities in their dispute resolution mechanisms, the great diversity of Indigenous groups in North America means that there will inevitably be differences between nations as well.[43]

Restorative justice as an alternative to civil litigation

Some academic commentators have suggested that adopting alternative dispute resolution (ADR) measures may be a more culturally appropriate and efficient manner in which Indigenous claimants can seek redress.[45] ADR approaches are generally more flexible, allowing claimants to break free from the rigidity of the tort law framework, which may allow greater acceptance of Indigenous legal orders.[46] Commentator Maegan Hough has advocated for a restorative justice-based approach to dispute resolution for Indigenous claimants in the context of residential school litigation.[46] In describing restorative justice, Magean Hough stated that:[47]

Broadly, restorative justice programs seek “to establish or re-establish social equality in relationships” between individual wrongdoers and victims, but also groups and communities, and to look beyond isolated disputes to the underlying conflict and context of the wrongdoing.

There is tangible support within Canadian law for the integration of restorative justice programs as an ADR measure for civil wrongs, as the Canadian criminal justice system has already adopted and integrated restorative justice principles such as sentencing circles and victim impact statements.[47]

United Nations Declaration on the Rights of Indigenous Peoples

Reviving Indigenous law as a source of Canadian law
Here, lawyers from the OKT Podcast break down the United Nations Declaration on the Rights of Indigenous Peoples and speak on its implications for the relationship between Canada and Indigenous peoples.[48]

The United Nations Declaration on the Rights of Indigenous Peoples is an international human rights instrument outlining the rights of Indigenous peoples across the globe.[49] It contains 46 articles that set out collective and individual rights as they pertain to Indigenous peoples, with the goal of protecting their survival, dignity and well-being.[49] While it is not a legally binding document, it may influence state laws.[49] Overall themes underlying the Declaration's provisions include

  • the right to self‐determination;
  • the right to be recognized as distinct peoples;
  • the right to free, prior and informed consent; and
  • the right to be free from discrimination.[49]

Canada was one of four countries (along with Australia, New Zealand, and the United States) that initially voted against adopting the Declaration in 2007, voicing concerns that it would be incompatible with national law. In 2010, Canada formally endorsed the document but still treated it as purely aspirational. In 2021, the United Nations Declaration on the Rights of Indigenous Peoples Act received royal assent in Canada, affirming that the government will take the steps necessary to ensure that Canadian laws are made consistent with the Declaration.[49]

Several articles in the Declaration are particularly relevant to the promotion of Indigenous legal orders and Indigenous communities' right to self-govern. For example, article 4 states that "Indigenous peoples, in exercising their right to self-determination, have the right to autonomy or self-government in matters relating to their internal and local affairs, as well as ways and means for financing their autonomous functions."[50] Article 5 emphasizes Indigenous peoples' right to "maintain and strengthen their distinct political, legal, economic, social and cultural institutions".[50] Article 27 provides that "[s]tates shall establish and implement, in conjunction with indigenous peoples concerned, a fair, independent, impartial, open and transparent process, giving due recognition to indigenous peoples’ laws, traditions, customs and land tenure systems, to recognize and adjudicate the rights of indigenous peoples pertaining to their lands, territories and resources...."[51]

In the news
Vancouver unveils its 5-year ‘UNDRIP’ Action Plan
The City of Vancouver announced a 5-year plan to implement UNDRIP. The plan features 79 calls to action and was formed in collaboration with the Musqueam, Squamish and Tsleil-Waututh First Nations.[52]

The sentiments of the Declaration are echoed in case law. In First Nations Child and Family Caring Society of Canada et al. v. Attorney General of Canada (for the Minister of Indian and Northern Affairs Canada), the Canadian Human Rights Tribunal found that the Department of Indigenous and Northern Affairs’ provision of child welfare services on First Nations reserves was discriminatory.[53] Although "self-government" is not explicitly mentioned in the judgment, it implies that First Nations have a right to make decisions about child and family services in their communities because "in order for child welfare services to meet their cultural, historical, and geographical needs and circumstances as required by the decision, First Nations people must necessarily be the ones to design and control such services."[54]

Discussion questions

  • How should the principle of reconciliation influence the judicial interpretation of common law and statutory rules? How should it influence lawyers’ approaches to civil litigation?
  • In this era of reconciliation and given the disproportionate impact of climate change on Indigenous communities,[55] how should Indigenous legal traditions inform courts’ approaches to climate change litigation? How should they influence the development of the common law more generally?
  • In a news interview, Māori rights activist Mike Smith describes his work as engaging with iwi communities in Aotearoa New Zealand to spread climate change awareness and working with governments to design national policies. Is private law litigation an effective means of achieving these goals?
  • Read Prof. Drake’s proposal for an institution that facilitates dispute resolution between Canadian governments and Indigenous peoples grounded in Indigenous constitutionalism. What opportunities does this proposal hold over civil litigation and alternative dispute resolution procedures?


  1. ↑ Coyle, Michael (August 2022). "Indigenous Legal Orders in Canada - a literature review (updated to August 2022)". Law Publications. 92: 1.
  2. ↑ 2.0 2.1 The Constitution Act, 1982, Schedule B to the Canada Act 1982 (UK), 1982, c 11, s 35(1).
  3. ↑ Law Commission of Canada (August 2006). "Justice Within: Indigenous Legal Traditions". LCC: 2, 9.
  4. ↑ See e.g. Anderson v. Alberta, 2022 SCC 6 (§25.1.2); Restoule v. Canada (Attorney General), 2021 ONCA 779.
  5. ↑ Coyle, Michael (August 2022). "Indigenous Legal Orders in Canada - a literature review (updated to August 2022)". Law Publications. 92: 14–15.
  6. ↑ Law Commission of Canada (August 2006). "Justice Within: Indigenous Legal Traditions". LCC: 29.
  7. ↑ Brierley, John Ec (6 February 2006). "Common Law". The Canadian Encyclopedia.
  8. ↑ Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 25.
  9. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at paras 182–187.
  10. ↑ Mikisew Cree First Nation v. Canada (Minister of Canadian Heritage), 2005 SCC 69 at para 1.
  11. ↑ Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 9.
  12. ↑ Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 2.
  13. ↑ Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 2 citing British Columbia (Minister of Forests) v. Okanagan Indian Band, 2003 SCC 71 at para 40.
  14. ↑ Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 4.
  15. ↑ Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 3.
  16. ↑ Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 13.
  17. ↑ 17.0 17.1 Anderson v. Alberta, 2022 SCC 6 (§25.1.2) at para 27.
  18. ↑ Restoule v. Canada (Attorney General), 2021 ONCA 779 at para 2.
  19. ↑ Restoule v. Canada (Attorney General), 2021 ONCA 779 at paras 124, 227.
  20. ↑ 20.0 20.1 Restoule v. Canada (Attorney General), 2021 ONCA 779 at para 227.
  21. ↑ Ontario (Attorney General) v. Restoule, 2024 SCC 27 at para. 18.
  22. ↑ Ontario (Attorney General) v. Restoule, 2024 SCC 27 at para. 197.
  23. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1).
  24. ↑ Law Report (30 April 2024). "Tikanga: incorporating Māori concepts in NZ common law". Apple Podcasts.
  25. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§19.11.3) at para 4.
  26. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 5.
  27. ↑ Māori hub (14 July 2024). "Tikanga Customary practices guide". Victoria University of Wellington.
  28. ↑ 28.0 28.1 Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 177.
  29. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 180.
  30. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 179.
  31. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 182.
  32. ↑ 32.0 32.1 Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 188.
  33. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 187 citing Attorney-General v. Ngati Apa, [2003] NZCA 117.
  34. ↑ Smith v. Fonterra Co-op. Group Ltd, [2024] NZSC 5 (§25.1.1) at para 188 citing Takamore v. Clarke, [2012] NZSC 116;Trans-Tasman Resources Ltd v. Taranaki-Whanganui Conservation Board, [2021] NZSC 127; Ellis v. R (Continuance), [2022] NZSC 114. .
  35. ↑ JFK Law (12 January 2016). "Making Space for Indigenous Law". JFK Law.
  36. ↑ Modern Law - Droit Moderne (10 November 2022). "Episode 14: Reviving Indigenous law as a source of Canadian law". Apple Podcasts.
  37. ↑ 37.0 37.1 37.2 Coyle, Michael (11 September 2017). "Indigenous Legal Orders in Canada - a literature review (updated to August 2022)". Law Publications. 92: 4.
  38. ↑ Law Commission of Canada (August 2006). "Justice Within: Indigenous Legal Traditions". LCC: 9.
  39. ↑ 39.0 39.1 39.2 Drake, Karen (September 2020). "Indigenous Constitutionalism and Dispute Resolution Outside the Courts: An Invitation". Federal Law Review. 48 (4): 2.
  40. ↑ 40.0 40.1 Drake, Karen (September 2020). "Indigenous Constitutionalism and Dispute Resolution Outside the Courts: An Invitation". Federal Law Review. 48 (4): 3.
  41. ↑ Drake, Karen (September 2020). "Indigenous Constitutionalism and Dispute Resolution Outside the Courts: An Invitation". Federal Law Review. 48 (4): 9.
  42. ↑ Law Commission of Canada (August 2006). "Justice Within: Indigenous Legal Traditions". LCC: 3.
  43. ↑ 43.0 43.1 43.2 Neron, Robert (16 July 2024). "ADR in the Aboriginal Context". ADR Institute of Canada.
  44. ↑ Victor, Wenona (April 2007). "Alternative dispute resolution (ADR) in Aboriginal contexts: A critical review" (PDF). Canadian Human Rights Commission: 33.
  45. ↑ Hough, Maegan (2019). "The Harms Caused: A Narrative of Intergenerational Responsibility". Alberta L Rev. 56 (3): 858.
  46. ↑ 46.0 46.1 Hough, Maegan (2019). "The Harms Caused: A Narrative of Intergenerational Responsibility". Alberta L Rev. 56 (3): 858–859.
  47. ↑ 47.0 47.1 Hough, Maegan (2019). "The Harms Caused: A Narrative of Intergenerational Responsibility". Alberta L Rev. 56 (3): 859.
  48. ↑ OKT Podcast (2 May 2024). "OKT Podcast S1E2 - United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP)". Spotify.
  49. ↑ 49.0 49.1 49.2 49.3 49.4 Duhamel, Karine (8 September 2022). "The United Nations Declaration on the Rights of Indigenous Peoples". Canadian Museum for Human Rights.
  50. ↑ 50.0 50.1 United Nations General Assembly Session 61 Resolution 295. United Nations Declaration on the Rights of Indigenous Peoples A/RES/61/295 page 4. 2 October 2007.
  51. ↑ United Nations General Assembly Session 61 Resolution 295. United Nations Declaration on the Rights of Indigenous Peoples A/RES/61/295 page 8. 2 October 2007.
  52. ↑ CBC Vancouver (3 June 2024). "Vancouver unveils its 'UNDRIP' Action Plan". Youtube.
  53. ↑ First Nations Child and Family Caring Society of Canada et al. v. Attorney General of Canada (for the Minister of Indian and Northern Affairs Canada), 2016 CHRT 2.
  54. ↑ Metallic, Naiomi Walqwan (2018). "A Human Right to Self-Government over First Nations Child and Family Services and Beyond: Implications of the Caring Society Case". Journal of Law and Social Policy. 28 (2): 6.
  55. ↑ Reyes‑García, Victoria; et al. (8 January 2024). "Local studies provide a global perspective of the impacts of climate change on Indigenous Peoples and local communities". Sustainable Earth Reviews. 7 (1).
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